FILE No. V / NATIONS
VOLUME I · APRIL MMXXVI
Nations — what comparable jurisdictions actually collect
Volume V · International comparison
Benchmark
Norway (offshore gas, similar scale)
Period
FY 2023-24 / 2025 NPD estimate
Sources
NPD · NBIM · ATO
Caveats
See § C — addressing 'Norway isn't Australia'
§ Nations

Norway and Australia sell similar gas to similar buyers. Norway built a A$1.9 trillion fund. Australia did not.

Every gas-exporting nation in the world has chosen a way to tax its own resource. Norway is the cleanest like-for-like comparison: a small, advanced economy with a large offshore gas industry. The figures below are from the Norwegian Petroleum Directorate, Norges Bank Investment Management, and the Australian Taxation Office. We have not invented multipliers, projected counterfactual revenues, or built a comparison table out of countries we cannot source.

The same petroleum revenue, settled three ways

If you are a Norwegian, the gas under your seabed has a name on it. Yours.

01 As a country Sovereign-fund stock, 2024
🇳🇴 A$1.9T Government Pension Fund Global
🇦🇺 A$0 No sovereign fund from gas
02 Per citizen, fund stake Fund balance ÷ resident population
🇳🇴 ≈ A$350K A family of four: ≈ A$1.4 million
🇦🇺 A$0 A family of four: A$0
03 Per citizen, this year Government petroleum revenue ÷ population, 2024–25
🇳🇴 ≈ A$18,000 NOK 656 B ÷ 5.55 M residents
🇦🇺 ≈ A$56 A$1.5 B PRRT ÷ 27.0 M residents

Sources: Norges Bank Investment Management (fund balance, end-2024) · Norwegian Petroleum Directorate (2025 government petroleum revenue estimate) · ATO (PRRT statistics, FY 2023-24) · ABS & SSB (population). Ratios computed on this site; the working is in the press kit, § C.

§ A The two regimes

What each country charges, statutorily, on a profitable petroleum project.

Norway's regime is two-tier. Australia's is two-tier on paper, but the second tier (PRRT) defers indefinitely against uplifted exploration deductions.

🇳🇴
Norway
Petroleum Tax Act 1975
+ 56%
Special Petroleum Tax
Applied to petroleum profits, in addition to corporate tax. Uplift on new investment limited to ≈ 5.4% / year over 4 years.
22%
Corporate Income Tax
Standard rate, applied to taxable income.
78%
Statutory marginal rate on petroleum profits

Plus the SDFI: the Norwegian state holds direct equity in producing fields through the State's Direct Financial Interest. The state takes its share of revenue and bears its share of cost in cash, alongside corporate tax and PRT.

🇦🇺
Australia
PRRT Assessment Act 1987 + ITAA
40%*
Petroleum Resource Rent Tax
Statutory rate 40% on taxable petroleum profits — but exploration deductions uplift at LTBR + 15 pp (≈ 19% / year, compounded), carried forward without time limit. Most LNG projects pay nothing.
30%
Corporate Income Tax
Standard rate. Itself reduced by depreciation, accelerated capital allowances, and group losses.
< 30%
Effective government take, all instruments combined

No state equity. The Commonwealth takes no production share, no equity stake, no royalty on offshore Commonwealth-waters projects (most of the LNG fleet). State royalties apply to onshore projects only.

Sources — Norway: Norwegian Petroleum Directorate, "The Petroleum Tax System" (norskpetroleum.no). Australia: PRRT Assessment Act 1987 (Cth); effective-take figure from The Conversation, April 2026, citing Australia Institute analysis. The 5.4% Norwegian uplift figure is the post-2022 capped-uplift rate; it replaced a higher uplift after a regime overhaul.

§ B What that produced

What each country collected — and what it built with the proceeds.

Five rows. Each cell sourced. The contrast is not a model — it is a consequence of the regimes in § A.

Norway Australia
Statutory marginal rate on petroleum profits 78% ≤ 70% on paper · < 30% effective
2025 estimated government petroleum revenue NOK 656 B
≈ A$100 B
A$1.5 B PRRT
+ ~A$3 B state royalties (CSG / WA)
Sovereign wealth fund A$1.9 T
Government Pension Fund Global
— none from gas
Future Fund is a PS-pension reserve
Per-citizen sovereign-fund stake ≈ A$350,000 A$0
State equity in producing fields SDFI — Norwegian state holds direct equity in most fields None

Sources — Norway figures: Norwegian Petroleum Directorate (2025 estimate), Norges Bank Investment Management (fund balance, end-2024), Australia Institute 2023 analysis. Australia figures: ATO PRRT statistics (FY 2023-24), state-royalty estimate from WA / QLD revenue offices.

§ C The standard rebuttal

"You can't compare Norway to Australia."
We agree. That isn't the argument.

When this comparison is made publicly, the industry response is consistent: different geology, different industry structure, different country, different era. All of that is true. None of it is the point. The point is narrower, and harder to deflect.

What we are not arguing

That Australia should copy Norway's tax code line for line. That the Bass Strait and the North Sea are the same basin. That a country of 5.5 million and a country of 27 million should run identical fiscal policy.

What we are arguing

That the terms a sovereign government sets with a multinational gas company are negotiable — and that the industry's claim that any tightening will cause projects to leave is not supported by what has happened in countries that have tightened.

01
"Norwegian fields are easier — different geology."

Some are. Many are not. Snøhvit sits 140 km offshore in the Barents Sea above the Arctic Circle, with subsea wellheads in 250–345 m of water and a 143 km pipeline to a liquefaction plant on Melkøya. Aasta Hansteen is in 1,300 m of water — Norway's deepest. Johan Castberg came online in 2024 in iced-over waters 100 km north of Snøhvit. None of these are the easy fields. They were developed under the 78% combined rate, and they were developed anyway.

02
"Norway has Equinor — Australia doesn't."

Correct. Norway built a state-owned operator in 1972 (then Statoil) as a deliberate act of policy. Australia did not. That is a choice the Australian Parliament made — and could revisit. The Norwegian SDFI, which holds direct state equity in producing licences without being a company, is a separate instrument again. Both were designed at a desk. Neither requires geology to copy.

03
"The companies will pull out if you tighten the screws."

The companies operating on the Norwegian shelf today, under the 78% combined rate, include Shell, ExxonMobil, TotalEnergies, ConocoPhillips, Aker BP, Wintershall Dea, Vår Energi — the same names that operate on the North West Shelf. They have not left. They have, in several documented cases, lobbied hard against rate increases, lost the argument, and stayed. Norway raised the special tax in 2022 in response to windfall prices. Investment continued.

04
"It's a different era — you can't change the rules now."

The PRRT was legislated in 1987. The uplift rate at the centre of the current debate (LTBR + 15pp, compounded, no time limit) was set then and has not been revisited despite a Treasury review (Callaghan, 2017) recommending change. "You cannot revisit the settlement" is not an argument from physics. It is an argument from inertia.

The Norway comparison does one job on this site: it forecloses the move that says nothing else is possible. Once that move is foreclosed, the live question is the one § A & § B set out — what would Australia choose, and from whom.

§ D What the comparison implies

Three things the Norwegian record establishes.

None of them are new arguments. All three are conclusions of public Australian policy reviews in the last decade.

  1. i.

    Higher rates do not deter petroleum investment.

    Norway's combined statutory rate has sat at or above 70% for decades. Equinor — majority state-owned — remains one of the most consistently profitable European energy companies. The lobby's claim that higher Australian taxes would drive operators away is not supported by the Norwegian record.

  2. ii.

    An uplifted-deduction regime is a policy choice, not a market constraint.

    Norway taxes new investment with a capped, time-limited uplift (≈ 5.4% / year, 4 years). Australia uplifts exploration expenditure at LTBR + 15 percentage points, compounded, with no time limit. The Callaghan PRRT Review (2017) recommended reducing the Australian uplift. The recommendation has not been adopted.

  3. iii.

    State equity changes the bargaining position.

    Norway's SDFI gives the state a direct line of sight into project economics — costs, revenue, and transfer-pricing — because it sits on the cap table. Australia has no equivalent instrument. Every PRRT calculation Australia does is from outside the project.